Europe
Transfer Pricing
Europe
Americas
Americas
Asia-Pacific
Asia-Pacific
Americas
Europe
Multinational
Asia-Pacific
India’s final transfer pricing master file rules retain unique flavor
Jitendra Jain, Executive Director, PricewaterhouseCoopers, discusses final Indian rules for multinational taxpayers, released October 31, on the implementation of the transfer pricing master file and country-by-country report, noting that important changes were made to the earlier, draft version of the guidance. . .
Americas
OECD publishes peer review reports on tax dispute resolution in US, Belgium, Canada, Netherlands, Switzerland, UK
The OECD has today published peer review reports that critique the tax treaty dispute resolution process of six countries: United States, Belgium, Canada, the Netherlands, Switzerland, and the United Kingdom. The peer review was conducted by the “Inclusive Framework on BEPS,” comprised of over 100 countries that have pledged to . . .
Featured News
OECD releases revised discussion drafts on attribution of profits to PEs, profit splits
The OECD today released revised draft guidance on the attribution of profits to permanent establishments (PEs) as well as revised draft transfer pricing guidance on profits splits. Both discussion drafts replace earlier drafts . . .
Council of the EU
EU agrees to mandatory binding arbitration of tax disputes
Davide Anghileri of the University of Lausanne discusses an ECOFIN deal, reached May 23, for a directive that will create a new system for resolving double taxation disputes between the EU States; he also provides an update of EU discussions on adopting a common corporate tax base (CCTB) . . .
Americas
Cayman Islands, Belize to adopt BEPS international tax standards
The Cayman Islands and Belize have become members of the “Inclusive Framework on BEPS,” the OECD announced today. The inclusive framework is a group of countries that have pledged to put into place minimum standards aimed at preventing tax avoidance and improving . . .
Europe
Americas
Americas
Europe
Ireland releases Q&As on country-by-country reporting for multinationals
Irish Revenue has released a set of frequently asked questions relating to the country-by-country reporting requirements for multinationals under Irish legislation . . .
Asia-Pacific
Draft Australia diverted profits tax legislation released for public comment
The Australian government today released draft diverted profits tax legislation, designed to stop large multinational businesses from artificially . . .
Andorra
Andorra becomes 40th non-OECD/G20 country to join “inclusive framework” for BEPS implementation
Andorra has become the 40th country that is neither an OECD nor G20 member to join what is known as the inclusive framework for BEPS implementation, a group of countries that have pledged to adopt measures, designed by the OECD and G20 in the base. . .
Asia-Pacific
Singapore issues country-by-country reporting guide assist MNEs
Singapore’s tax authority has prepared a tax guide addressing how large multinationals can fulfill the obligation to prepare and submit country-by-county reports . . .
Europe
Italy: new circular outlines tax deductibility of blacklist costs
Italy’s tax authorities on September 26 issued a circular clarifying new rules on the deductibility of costs associated with transactions between Italian resident individuals or entities and businesses operating in blacklisted tax haven countries, writes guest author, Davide Anghileri . . .
Featured News
OECD sets criteria for labeling countries as “non-cooperative” tax jurisdictions, previews coming tax guidance
The OECD has devised proposed criteria for determining if a country is a “non-cooperative” tax jurisdiction, an official said during a July 12 OECD webinar. OECD officials also discussed plans to release further tax and transfer pricing . . .
Featured News
New OECD country-by-country reporting guidance provides for voluntary filing
The OECD today issued further guidance implementing the new transfer pricing documentation and country-by-country (CbC) standards of action 13 the OECD/G20 base erosion profit shifting plan. The guidance is designed to ensure consistent implementation . . .
Multinational
Americas
Medtronic wins transfer pricing dispute in Tax Court
Medical device manufacturer Medtronic on June 9 won its transfer pricing dispute with the IRS in Tax Court, beating back the IRS’s claim that the medical device manufacturer should have reported increased US royalty payments and 2005 and 2006 from a related Puerto Rico . . .
Africa
Customs
WCO valuation committee approves key case study on interplay of customs valuation and transfer pricing
Joel Cooper, co-head of international transfer pricing at DLA Piper, London, reports on a new WCO instrument that addresses use of transfer pricing documentation in assessing customs values. . . .
Asia-Pacific
Americas
Featured News
Americas
Featured News
Europe
EU Court upholds German transfer pricing law, says non-arm’s length loan guarantee may be justified
Davide Anghileri of the University of Lausanne discusses Court of Justice of European Union’s May 31 decision in Hornbach-Baumarkt which concluded that German transfer pricing legislation is valid and found that the role of the parent company as a shareholder of a non-resident company may be taken into account in assessing a non-arm’s length related-party transaction . . .
Featured News
Europe
Featured News
OECD releases comments on international tax rules for digital economy
The OECD on October 25 released public comments from 52 individuals and groups on the design of new international tax rules for digital firms. The comments aim to help an OECD task force prepare an interim report on the issue, to be presented to G20 finance ministers in April 2018. It is widely acknowledged that the current . .
Europe
Asia-Pacific
